GUIDELINE  SERIES
           OAQPS NO.   1.2-011
              DRAFT
    GUIDELINES FOR DETERMINING THE NEED FOR
    PLAN REVISIONS TO THE CONTROL  STRATEGY
         PORTION OF THE APPROVED
         STATE IMPLEMENTATION PLAN
                                            3OC
   US. ENVIRONMENTAL PROTECTION AGENCY
     Office of Air Quality Planning and Standards

       Research Triangle Park, North Carolina

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           OAQPS  1.2-011

GUIDELINES FOR DETERMINING THE NEED FOR

PLAN REVISIONS TO THE CONTROL  STRATEGY

         PORTION OF THE APPROVED

       STATE IMPLEMENTATION PLAN
                 DRAFT
                                 Analysis  and Reports  Section
                               Standards  Implementation  Branch
                             Control  Programs Development  Division
                                   Office of Air Quality
                                  .Planning and Standards
                                      November 30,  1973

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                      TABLE  OF CONTENTS

  I.   Introduction	1
 II.   Responsibilities in Implementing Plan  Revisions.  ...   3
III.   Procedures  for Determining  Whether  a SIP/Control
      Strategy Needs to be Revised  	   5
      A.   Identification of  Problem Air Quality  Control
          Regions	5
      B.   Evaluation of Data 	   7
      C.   Analysis of Control  Strategy 	 10
      D.   Reporting of Results	13
 IV.   Procedures  for Requiring Plan Revisions. . v	 14
      A.   Plan Revision Documentation.	14
      B.   Notification and Concurrence 	 15
      C.   Notification of State	15
      D.   Plan Submittal	17

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I.   Introduction
        Section 110(a)(2)(H)  of the Clean Air Act,  as  amended requires  that
    State Implementation Plans (SIP's) "provide for  revision,  after public
    hearings,  of such plan (1) from time to time as may be necessary to take
    account of revisions of such national primary or secondary ambient  air
    quality standard or (2) the availability of improved or more  expeditious
    methods of achieving such primary or secondary  standard;  or (3)  whenever
    the Administrator finds on the basis of information available to him
    that the plan is substantially inadequate to achieve the  national ambient
    air quality primary or secondary standard which it implements."
        While  the Act specifically identifies three (3) reasons why  SIP's can
    and must be revised, this guideline deals mainly with plan revisions to
    the control strategy portion of the SI? which are  deemed  necessary  on the
    basis of information available to the Agency which indicates  the approved
    SIP/control strategy is inadequate to attain the national  standard  it
    implements.  While the reasons for requesting a revision  may  be  different,
    the administrativa procedures for requesting a  revision under each  of the
    three cases is the same.
        EPA must exercise good judgement in determining whether the  control
    strategy portion of an approved SIP is inadequate  to achieve  national
    standards  on a timely basis.  It should be the  Agency's policy to request
    such plan  revisions only  where they are clearly necessary.  Frequent
    revisions,  particularly where they affect emission control requirements,
    are undesirable in that they confront source owners with  a "moving  target."
    In an attempt to assist in identifying those Regions that may need  plan
    revision,  the Standards Implementation Branch (SIB) of the Control  Programs

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Development Division, Office of Air Quality Planning and Standards,  has
developed a PLAN REVISION MANAGEMENT SYSTEM (PRMS)  which compares  actual
measured air quality levels, submitted by States  as part of their  quarterly
reports, with projected emission reductions required by the adopted  emission
limitations contained in the approved SIP.   The system is capable  of moni-
toring the progress in each AQCR and when ambient air quality  levels do not
follow the anticipated reductions,  the region  will  be flagged  as a "potential
problem region."  Further investigation by  regional personnel  will be necessary
prior to the determination of whether a plan revision is needed.

     The majority of the information that will be needed to formulate the
  decision as to whether the control strategy is  inadequate to achieve
  the national standards will be obtained from the quarterly and semiannual
  reports (40 CFR 51.7, Report, August 3, 1973).   Of course, other informa-
  tion such as the Quarterly Trends Report, daily contacts with State and
  local agencies, compliance information (see enclosure 1), etc.,  should
  also be used in the determination.  Air quality data will be the key
  indicator of a "potential problem region," as measured air quality will
  be the real   indicator of attainment of the NAAQS.  However, emission
  data, enforcement and compliance information, etc. must be reviewed to
  determine the adequacy of the control strategy to attain the national
  standard  in relation to the measured air quality levels.   \
                                                                j
      This guideline sets forth (1) the procedures  for determining when
  a revision to the control strategy portion of the SIP is necessary (2)
  the procedures for notifying the State that a plan revision is  necessary
  and (3) the responsibilities of headquarters and regional personnel in

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    implementing the:e procedures.
II.  Responsibilities in Implementing Plan  Revisions
         In cases where revisions  to the control  strategy  are  necessary
    because new information indicates that the approved  control  strategy
    is inadequate to attain the  national  standards,  the  Regional Office
    will  be primarily responsible  to review available  information  and
    recommend any action, if appropriate,  to call  for  a  plan  revision.
    Recently, in response to a request by  the Assistant  Administrator
    for OAWP, the Administrator  delegated  his authority  to request a plan
    revision to the Regional Administrators'through  EPA  Order  1270.5 (see
    enclosure).  In cases where  the requested revision would significantly
    affect emission control regulations,  or the enforcement thereof,
    Regional Administrators should obtain  the concurrence  of  the Deputy
    Assistant Administrator for  Air Quality Planning and Standards and the
    Deputy Assistant Administrator for General  Enforcement prior to request-
    ing that the State make the  revisions.   Further, where the requested
    revision would have significant national  policy  implications or would
    establish a significant precedent (the first time  a  substantial type
    of action is taken anywhere),  the above Deputy Assistant Administrators'
    concurrences should be requested.   Insofar as  other  revisions  are concerned,
    Regional Administrators should  simply  notify the above Deputy  Assistant
    Administrators of requests trade.
        OAWP/OAQPS will  provide overall assistance  to the Regions  in this
    area.  A  Plan  Revision  Management  System is  in  operation which  will provide
    a  review of the  air quality  data  received from each  State  and  local agency
    and identify  those  Regions where  it  appears  adequate progress  is not
    being  made  in  attaining the  air quality standards  as provided  in the

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implementation of the SIP.  In addition, OAQPS wi.ll publish the Quarterly
Trend Reports, Quarterly Air Quality Summary Statistics and the Annual
National Emission Report.  These reports will serve to assist the
Regional Offices; as the Regional Offices will have the primary responsi-
bility for determining whether a plan revision is needed.
     Once tne plan revision has been submitted by the State, the Regional
Offices (as outlined in the September 14, 1972, Sansom/Quarles memo of
understanding, as revised in 1.2-005 (revised) of the OAQPS Guideline
Series) are further responsible to review, to recommend approval/dis-
approval and promulgation and to prepare the Federal Register package
associated with any measures which have been determined to be necessary
to assure that the national standards will be achieved.
     Headquarters (OAWP/OAQPS and OEGC/DSSE) will provide technical and
policy assistance to assure national uniformity on various issues insofar
as appropriate.  Headquarters will also have the responsibility to review
and to concur or nonconcur with the recommended action for each revision.
     The Agency responsibilities are somewhat different in those cases
where plan revisions are necessary to take account of new or revised
national standards.  In this case, OAWP has the primary responsibility
of preparing and publishing in the federal Register (1) the new or
revised national standards and (2) specific guidelines en what actions
States need to take to develop, adopt and submit an approvable plan to
implement the new or revised standard.   In general, all States will be
required to subnit a plan for a new national standard or will be required
to revise their existing SIP's to consider a revised national standard.
After OAWP has published guidelines for the dc-velopmont of approved SIP's,

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     the Regional Offices are then responsible to assist States  in the
     development of SIP's etc.
          In situations where the SIP regulations (40 CFR Part 51) are
     modified in such a way as to affect the control  strategy requirements
     (such as the recent action in relation to maintenance of standards
     (40 CFR 51.12, June 18, 1973) and the  pending action in relation  to
     tall  stacks) OAWP and Regional  Office responsibilities are  identical
     to those described for a new or revised standard.
III.  Procedures for Determining Whether a SIP./Control Strategy Meeds  to  Be
     Revised
     A.  Identification of problem air quality control  regions
          It is difficult to develop comprehensive guidance on exactly
     how to detemine whether a control strategy will need to be revised.
     While there may be a few situations where it is  obvious that a plan
     revision is necessary, in general it will be a difficult task to
     determine that a plan is inadequate to attain the  standards prior  to
     the established attainment date.  The problem is to determine whether
     AQCR's are progressing satisfactorily in relation  to the emission  limi-
     tations contained within the SIP.  To this end,  a  Plan Revision  Manage-
     ment  System (PRMS) was developed to track the progress being made  by
     States in implementing their SIP.  PR/MS provides a means for effectively
     combining information contained in SAROAD (air quality) NEDS (source
     emissions), and CDS (enforcement and compliance  information) to  compare
     measured progress against expected progress.
          This system is designed to monitor the progress of actual air
     quality levels, obtained from the quarterly reports, in relation to the
     anticipated air quality reductions which should  occur as a  result  of

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 compliance with approved emission limitations.  If the difference between
 the observed  and projected air quality levels exceed certain specified
 limits, then  the site is "flagged" as a "potential problem."  A number of
 flagging  levels or tolerance limits are incorporated in the system to
 indicate  that the site either has acceptable progress or is having a minor,
 major or  significant problem toward attainment of the NAAQS.  The tolerance
 limits were developed through the application of statistical quality control
 techniques which allow for the many variables associated with measured air
 quality concentrations. (See Figure 1)
    Once  a "potential problem region" is identified, OAQPS will notify
 the appropriate Regional Office.  This will be done on a semiannual  basis.
 The Regional Office will be responsible for investigation and further assess-
 ment of the problem.  The Regional Office should also report their findings
 to OAQPS  indicating the action they have taken or plan to take.
  .  While the PRMS will provide a mechanism to identify "potential problem
 regions"  from an analytical point of view, the Regional  Offices should be
 more intimately aware of the status of Regions within their States.   Thus,
 the Regional Offices may be aware of other AQCR's not currently being
 analyzed  by the PRMS which should be reviewed to determine if the plan is
 adequate  to attain the NAAQS by the specified data for attainment.
    Currently, there are 17 AQCR's contained in the PRMS.  An additional
 50 Regions will  be included in the system by January 1974.  The additional
 50 Regions that were selected for analysis were based on recommendations of
 the Regional Offices as to those AQCR's which should be reviewed to  insure
 that adequate progress is  being made toward attainment of the standards.
By mid-1974, 50 more AQCR's are scheduled to be included in the PRMS.   Thus,
by July 1974,  117 Regions  will  be analyzed.   The Regional Offices should

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                        Figure  1
                PLAN REVISION  MANAGEMENT SYSTEM
                      Particulate  Matter
Emissions
(1000 tons/year)       150

                      100

                       50
                       1970   1971    1972    1973    1974   1975   1976   1977
Air quality
(yg/m3)
150

100

 50

  0
                                                       Tolerance limits
                                                             Projected air
                                                                quality
                       1970   1971    1972    1973    1974   1975   1976   1977
                                           Calendar Year

                     "Measured air quality
Step
#1  Calculation of emission reduction (NEDS, Emission  Regulations)
#2  Review of compliance dates (SIP,  CDS,  Emission  Regulations)
#3  Projection of air quality
#4  Establishment of tolerance limits or boundaries
#5  Measured air quality trend (SAROAPN

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indicate to OAQPS those AQCR's that they believe should be reviewed to
determine the possible need for plan revisions.
     It is understood that air quality levels throughout an AQCR are
highly variable and that each monitoring site within the region must
have levels at or below the national standards by the specified date
for attainment to be in compliance with the Act.  The PRMS analyzes all
monitoring sites within SAROAD for the particular AQCR in question to
determine if adequate progress is being made.  Thus, the system is capable
of defining the problem on a much smaller scale than the entire AQCR.
While most of the'region may be showing adequate progress, a few sites,
located in areas of maximum concentration, may be deviating from the
desired air quality levels.  Review of these sites will allow the Agency
to take a much closer look at the real problem areas.  Because the R.O.
may only be required to review a very few problem sites, more effort can
be placed upon those areas within an AQCR which appear to-.be having the
most difficulty 'in attaining the standards.  It is believed'at ^his time
that it will  not be necessary in most cases to require a major plan
revision for an entire AQCR.  The revision or additional action can be
tailored to a minimum number of sources to give the maximum amount of
benefit toward attainment of the standards.  Thus, a review to determine
the adequacy of the progress for a region should be done on a site by site
basis.
B.  Evaluation of Data
     The review of problem monitoring sites should include three basic
items.   Is the data valid?  What were the meteorological conditions during
the reporting period?  Is the control strategy for the region adequate to
correct the problem at this site?

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     The validity of the air quality data is  the  major item  in  the
review of potential problem sites.   Monitoring  and  Data Analysis  Division,
OAQPS is preparing several  guidelines  to assist  in the validation of air
quality data.  (See enclosure #3)
     While EPA should generally be  confident  of the validity of the  air
quality data submitted by State and local agencies, it is  also  necessary
to review the validity of specifid  data especially  those data which  indi-
cate the need for plan revision.  The Regional  Office  should refer to the
guidelines mentioned above for the  specific items that must  be  reviewed
to verify the data.  However, basically these steps should include:
     a.  Discussion with the State  or local agency  to  verify their
         confidence in the submitted data.
     b.  Determination that the State or local  agency  laboratory  or
         quality control procedures are adequate.
     c.  Determination that the sampling instrument that was used to
         measure the data was calibrated and  operating properly.
     d.  Review the strip chart or  other record of  the measurement to
         verify the reported values.
     e.  Determine if the sampling  method by  which  the data  were  measured
         is reliable and in accordance  with the specified  reference method
         or equivalent.
     f.  In certain cases, it may be  necessary  to visit the  monitoring site
         to determine its representativeness.   Does it meet  EPA criteria
         for location of ambient monitors?  Are surrounding  structures or
         buildings causing unusual  air  flow patterns near  the sampler?  Is
         the sampler influenced by  emissions  from the  chimney or  incinerator
         of the building on which the sampler is  located,  or is the sampler

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         on a building surrounded by a heavily used unpaved parking lot?
         In summary, is the data collected by the site representative of
         air quality levels and should the data collected at the site-  be
         used as a basis for developing a control strategy?
     The last item in data validation is very important.   All  problem
sites should be reviewed in detail. . It is suggested that each problem
site be visited to determine its representativeness and to see what local
sources, if any, may be causing the major impact upon a particular receptor.
     If after a review of the above items it is determined that the air
quality values are valid then a review of the meteorological  conditions
should be conducted.  If the frequency and duration of inversions and
stagnations were unusually high, air quality could be higher than normal.
Unusually warm or cold weather will result in a change in fuel  use which
may increase ambient levels above normal.  Snow or ice storms  may be  assoc-
iated with excessive sanding or salting of streets,  and thus  increase
particulate matter concentrations.   Long periods  of dry weather may also
.increase the parti cul ate matter concentrations.  .
     The review of air quality data should also attempt to identify if
high concentrations were caused by unusual, events, such as local  construc-
tion or demolition activity, fires or perhaps control  equipment malfunction
or shut-down which could temporarily cause abnormally high ambient concen-
trations.   Data collected during abnormal situations should not be used
as a basis for requiring plan revisions.  If data are determined to be
"abnormal" or invalids  or that they represent unusual  circumstances,  such
data should be reported so that the SAROAD data bank users are properly
notified of these conditions.

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     After the air quality data has been validated and the  unusual  meteor-
ological conditions have been investigated,  the Regional  Offices  should
make an attempt to obtain the very latest air quality concentrations  for
the site in question.   Because of the lag in processing the air quality
 data from quarterly reports, the SAROAD system may be as much as two
 to four quarters behind the current air quality levels;  therefore, the
 Regional  Offices are  encouraged to obtain the very latest  data possible
 for the sites in question and submit this data to the PRMS so that an
 updated analysis can  be performed to assure that we have the latest  data
 possible upon which to base the analysis for determining adequate  progress.
 The PRMS system has been developed with the capability to  temporarily
 accept selected data  independent of the SAROAD system so that the  best and
 most up-to-date information is available for the Regional  Office review.
 Attempts should be made by the Regional Offices to see that data from
 those monitoring sites with potential  problems receive the highest priority
 by attempting to have the data from those sites reduced and submitted to
 SAROAD as quickly as  possible.
 C.  Analysis  of  Control  Strategy
    With  the  addition  of the  latest  air quality data,  a comparison of the
 trends  in  air quality  levels  at the  site  in question, with the air quality
 trends  noted  at  other  sites within the  Region  (State,  city or other area
where comparable  results  should exist)  should be made.  If the increase  or
 decrease is significantly different  than at the other sites, it would appear
 that a  localized  problem  exists.
    For the purposes of this guideline, let us assume that the site in
question is out-of-line with other ambient monitors in a region.   In  this

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case, it is recommended that a review of the  emission  data  and  compliance
status of sources within the immediate vicinity  of the site in  question
(say within a 1  to 3 mile radius—particulate matter and  sulfur dioxide
only, CO and oxidant would require much large area)  be made.  Points to
consider include:
    a.  Are some sources presently uncontrolled?   If so,  are  there
        control  regulations  with which these  sources must ultimately
        comply?   If not, do  these sources impact  sufficiently on  the
        site to  warrant a recommendation for  a plan  revision  to require
        further  emission limitations  on these sources?
     b.   If the  sources reviewed in (a)  have  applicable regulations that
        they must adhere to  at some later date,  is the anticipated erris-
        sion reduction  adequate to reduce ambient levels  to below the
        standard?
     c.   Do the  sources reviewed in (a)  have  applicable emission  limita-
         tions they must presently comply with?   Are the  sources  in
         compliance with the regulations?  If so, will  additional emission
         reductions be  needed to provide for  the  attainment of  the national
         standard?  If  the sources are not in compliance  with the emission
         limitation, is the  source on a compliance schedule?  Should EPA/
         State enforcement action be  initiated against the  source?
     d.   Have the sources in the vicinity of  the  site  in  question increased
         significantly?  Is  a plan revision necessary  to  compensate for
         increases in emissions?  What action is  needed in  relation to
         assuring that  the State adequately considers  ambient standards
         prior to their providing approval  to construct new sources?

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     Sometime during the investigation of potential  problems  there  should
be a review of the technique originally utilized for the AQCR to  correlate
the reduction in emissions with those in air quality levels.   Such  an
analysis was suggested in (a) and (b) above.   There  are a number  of approaches
available, each providing various degrees of accuracy which  can provide  a
relationship betv/een emission reductions and resultant ambient air  quality.
The selection of the appropriate method for determining this  relationship
depends upon the Regional Office resources available to address the problem.
Basically, these methods include:
    a.   Simple Rollback or proportional  model  which  assumed  that  as emis-
        sions are reduced or "rolled back" by one percent there is  a
        corresponding one percent reduction in ambient levels.  This is  a
        gross method of estimating the degree of emission reduction
        necessary to meet air quality goals and is by no means absolute.
        Most States used this method to develop their original SIP's
        because it is relatively simple and does provide a gross  estimate
        of the degree of a problem in a Region.   The method  is deficient in-
        that it does not consider meteorology, spatial  distribution of
        sources, nor the height of emission release; three important factors
        which influence ground level  concentrations.  It is  recommended  that
        in determining the need for a plan revision  that a more detailed
        approach be utilized in defining the relationship between emission
        reductions and air quality.
   b.    Modified Rollback procedures  have been recently developed by the
        Monitoring and Data Analysis  Division, OAQPS.   These  procedures
        provide a more sophisticated approach to the relationship of
        emissions to air quality.  This  procedure considers  meteorology,

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       spatial  distribution of sources, and the  height of emission
       release.   The  modified rollback provides a more accurate definition
       of  the  problem but also requires mere rofined omission data arid
       more nranpov/er.   The procedure is applicable to an urban area
       (city center)  problems.
   c.  Diffusion  Modelin? is the preferred predictive tool  available in
       relating .emission  to air quality duta.   A number of diffusion
       mc'-iels  (Air  Quality Display ifod^l, AQDM, and t!,ie Implementation
       Planning Program,  IPP) are available for defining urban situa-
       tions on an  annual basis.  Point source modsIs are also available
       for single source  short-term (1  hr and 24 hr)  situations.   Diffusion
       modeling requires  detailed emission, air quality and meteorological
       data to mathematically simulate the: emission/air quality relation-
       ship for a given region,   Voile there are certain limitations which
       restrict the use of diffusion nodals (lack of data} severe topo-   .. •
       ^ I':;[••:!! C  Vc i' I •:* i. i 'j\\'i ; •.. «..'w . / *  '.::<: ..'.; 1.1 ,'•.> U C.'»-:,';-• jj ;Xi V i--J'-.' >.i:'o IK..}!, i:\i'.\ , •••
       able approach  to predict resuVLir.g ch'ibient levels caused by the
       application of emission  "h'mitatioiis  0,1  emission sources.  Enclosure
       #4 provides a list  of  those  diffusion models which are  readily
       available to the Regional  Office through  the Tirr.e Sharing Option
       (TSO) computer facility.
D.  Reporting of Results
    The Regional Office will  be  notified 30 days  after the semiannual
report is due (February 15, August  15) of  those  potential problems and
should report on the status of their  investigation within 30 days  prior  to
the date due for the next  semiannual  report.   It  should be noted that the
above investigation of  potential  problem sites may require more than just
one semiannual  reporting  period  to  complete the  investigation.

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         Thus, the results reported to OAQPS for inclusion  into  the  Adminis-
     trators SIP Status Report may include several  different recommended
     actions.  These include:
         1.  Data determined to be invalid—work proceeding to  correct  and
             validate data.
         2.  Unusual meteorological  conditions  existed at the time and  more
             recent data indicated adequate progress.
         3.  No action, minor problem identified and resolved.
         4.  No action, new  projected air quality curve should  be developed
             to better define the trend in estimated air quality.
         5.  No action, pending further study—inconclusive or marginal
             analysis, too early to determine if problem exists.
         6.  More effective  implementation of new source review  procedures
             to restrict growth in certain areas is  needed.
         7.  EPA/State enforcement action is necessary
         8.  Plan revision is  needed.
         Procedures on how to  require a plan revision  for those  cases where
     the need has been identified are described in  Section  IV.

IV.   Procedures for Requi ring  PI an Reyi sions  .
         If a revision to  the  control  strategy  is determined to  be needed, the
     following actions are necessary:
         A.  Plan Revision Documentation
             The Regional  Office should document the reason why  the  plan
         revision is necessary, providing as much detail  as  possible on the
         discovery analysis  performed to determine  the need for  the  revision
         and identify, if  possible,  what source(s)  or  source categories should

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                              15
    be considered under the plan revision.  While it is hoped that
   , the approved SIP will be adequate to attain the national standard
    on a region-wide basis, it is highly likely that portions of some
    AQCR's ("subregions") will need further controls to achieve the
    standards.  Therefore, it is proper and necessary to identify those
    sources which may need to be considered when developing the plan
    revision.  This analysis should be discussed with the State and local
    agencies involved.
B.  Notification and Concurrence
       Where the requested revision would significantly affect emission
    control regulations, or the enforcement thereof, the Regional  Offices
    should obtain the concurrence of the Deputy Assistant Administrator
    for Air Quality Planning and Standards and the Deputy Assistant
    Administrator for General Enforcement prior to officially requesting
    a plan revision by the State.  Further, where the requested revision
    should have significant national policy implications or would establish
    a significant precedent, the above Deputy Assistant Administrators'
    concurrence should be sought.  In so far as other revisions are concerned,
    the Regions should simply notify the above Deputy Assistant Administrators
    of plan revision requests that have been made.
C.  Notification of State
         The Regional Offices should confer with the State and/or local
    agencies involved and advise them of the need for a revision.   The
    Regional  Administrator should officially notify the State (Governor)
    that a. revision is necessary*.  The notice should identify the following:
         (1)   Why the plan revision is necessary
*Thc issue of whether this should be done by letter or Federal  Register
notice will  be discussed in a separate memo rand urn.                    -

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(2)   What appears to be necessary to correct  the  deficiency
     i.e., what sources appear to cause the need  for further
     controls
(3)   What other portions of the SIP  must be revised  as  a
     consequence of the control  strategy revision.   These may
     include:
     (i)   Section 51.11 Legal   authority-- especially if
     transportation controls are deemed necessary
     (ii) Section 51.15 Compliance schedules  must be provided
     if new control  regulations  are  adopted.   The negotiated
     schedules  must be submitted at  the time  of submittal of
     new regulations.   However,  if the  regulation is immediately
     effective, then the schedules can  be submitted  as  a plan
     revision itself.
     (iii)  Section 51.17  Air Quality  Surveillance  —  The
     increase of ambient levels  may  indicate  a more  widespread
     problem than anticipated.   More ambient  sampling may be
     needed to  define  the extent of  the. problem and  monitor
     progress.
     (iv)  Section 51.21   Intergovernmental cooperation -- This
     section may need  to be revised  if  the State  delegates new
     responsibility to other State or local agencies to carry out
     portions of the plan.
   (v)   Section 51.20  Resources  -  New control  regulations may
   require additional  resources  for  enforcement purposes.  Such
   information  should  be  reported  with  the plan revision.

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                              17
            (vi)   Section  51.10  General  requirements - The control regula-
            tions  submitted  as part of the plan revision may indicate the
            need for a change in the date of attainment of the national
            standard.  Plan  revisions designed to attain the primary
            standard which require more stringenet controls than that
           which  is reasonably available, and which are more restrictive
            than the original SIP may justify the need for an extension  of
            up to  two years  (section 51.30).   One year postponements,
           40 CFR 51.32 (revised June 19, 1973)  may also be utilized.   It
           should also be noted that plans to attain the national secondary
           standard must do so within a "reasonable time."
      (4)  The time period  for submission of the revision to the Agency
            (Section 51.6(b), Revision) states that 'the plan shall be
            revised within 60 days following notification by the Adminis-
           trator, or by such later date prescribed by the Administrator
           after  consultation with the State."  Since a control strategy
           will  need to be developed and a compliance schedule determined
           and then have the regulations subjected to a public hearing
           and be adopted, it appears that four to six months  and perhaps
           longer will  be needed in most cases to revise the control strategy
           portion of the plan.
      (5)  The plan revision must be submitted in accordance with the pro-
           visions of 40 CFR 51.4, Public hearings and 51.6, Revisions.
D.  Plan Submittal
    Once the plan revision is submitted by the State,  the Agency procedures
outlined in the Sansom/Quarles memo of understanding of September 14.  1972,
as revised by OAQPS No.  1.2-005A, of the Guideline Series govern the review
and approval process.   Because of a recent court decision, however,  the

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                              18
Agency must now publish, in the Federal Register, the fact that a new
or revised SIP has been subm'tted to the Agency and that the public has
30 days to comment on the new plan.  These procedures will apply also
to all regulatory plan revisions.

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                   OUTLINE OF  RESPONSIBILITY
                              Air Quality
                               Data From/
                                States  /
                              Regional
                               Of fi ces
                                                        ther
                                                       AQCR's
                   RO
                Notified
                   of
                 Problem
Adequate
Progress
No Action
Within
Normal
Limits
                                                               iRO Review For i
                                                               [Potential     j
                                                               Problem
                                 Validate
                                   air
                                   uali
aag/   p
                           Data
                          Revised
                                                        Report  to
                                                        OAQPS Results
                                                        for Report to
                                                        Administrator
                                            RO
                                         nvastigate
                                          nd resolve

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Enclosure #1

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                              Enclosure #1



          Additional  Technical Publications to Assist in Regional  Office


                Investigation of the Need for Plan Revisions




1.  AP 78:  Guide for Air Pollution Episode  Avoidance


2.  AP 98:  Air Quality Surveillance Networks
                                     i

3.  APTD 0736:  Field Operators Guide for Automatic Air Monitoring  Equipment


4.  APTD 1085:  Air Quality Data Handling System Users  Manual


5.  APTD 1347:  Guidelines for Technical  Services of a  State Air  Pollution


                Control Agency


6.  EPA-RA-73-028c:  Guidelines for Development of a Quality Assurance


                     Program - Photochemical Oxidants


7.  EPA-RA-73-028c:  Guidelines for Development of a Quality Assurance


                     Program - Carbon Monoxide

                                      4

8.  EPA-RA-73-028c:  Guidelines for Development of a Quality Assurance


                     Program - Suspended  Particulate Matter

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MDAD

  NADB Reports

    a.  NEDS
        SAROAD
           quarterly reports
    b.  Quarterly summary ststisties air quality data
    c.  National Emission Report (Annual)
    d.  Site file directory - air quality monitoring (annual)
    e.  ISO/direct request using standard computer program
MRB

  a.
  b.
Trends Report (Quarterly)
Special analysis reports (quarterly)
  Reporting high measurement regions
DSSE  - (CDS/KAPINS)

  a.  Semiannual questionnaire used to update CDS
  b.  Region by region statistical output - data"summary by city/county/
        region/state, etc. (percent in compliance, etc.)
  c.  Source ID report - Basic Source Data
  d. ' Future schedule summary
  e.  Geographic locations
  f.  Action summary report
  g.  Status summary report
  h.  Source action summary
  j.  Overdue action report
GAD'

  Must be some reporting but '.-liable to identify specific items
SIB
  a.  Guidelines for dcmer ^.i.-j the need for a plan revision
  b.  RTI manual for P.I'iS analysis
  C.  Protocol for submitting new data and results of PRMS to R.O.

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Enclosure #2

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ENVIRONMENTAL
[PROTECTION               ORDER
AGENCY
               I
1270.5
                                                             October 15, 1973
                 DELEGATIONS OF AUTHORITY - AIR AND WATER PROGRAMS
                   DELEGATION OF AUTHORITY TO REQUEST STATES TO
                         REVISE STATE IMPLEMENTATION FLANS
 1.   PURPOSE.  This Order  delegates to the Regional Administrators  the
 authority to request States  to revise State Implementation Plans under
 Section 110(a)(2)(H)(ii)  of  the Clean Air Act.

 2.   BACKGROUND.   Section  110(a)(2)(H)(ii) of the Clean Air Act provides
 for  the revision of State Implementation Plans  (SIP's)•"whenever the
 Administrator finds on the basis of information available to him that the
 plan is substantially inadequate to achieve the national ambient air
 quality primary or secondary standard which it  implements."  In view of
 the  emphases on utilizing regional offices in supervising the SIP's, a
 delegation of authority to the Regional Administrators uo request  the
 revisions is in order.

 3.   DELEGATION.   The Regional Administrators are delegated authority to
 perform the responsibilities indicated above within their respective
 regions.

 4.   LIMITATIONS.

     a.  Revisions will be requested only when such  revisions are clearly
 necessary.
              •»
     b.  Where the requested  revision would affect emission control
 regulations significantly, or the enforcement thereof, Regional Admin-
 istrators should obtain the  concurrence of the  Assistant Administrator
 for  Air and Water Programs and the Assistant Administrator for Enforce-
 ment and General Counsel.

     c.  Where the requested  revision would have significant national
 policy implications or would establish a significant precedent, the
 concurrence of the aforesaid Assistant Administrators is required.
Dist:  Directives Distribution                                        initiated by: AF

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                                                              1270.5
                                                          October 15,  1973
    d.  Insofar as other revisions are concerned, Regional Administrators
should simply notify the two Assistant Administrators of requests made.
    e.  This authority may not be redeles
                                      Russell E.  Train
                                       Administrator

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Enclosure #3

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                                                                 Enclosure #3

              Guidelines on Ambient Trend Monitoring
              Monitoring and Data Analysis Division

1.  General guidelines for Regional Office monitoring programs
    PURPOSE:  General summary of existing ambient trend monitoring
              guidelines
2.  Guidelines for validation of Air Quality Data
    PURPOSE:  Steps to insure valid data
3.  Guidelines on interpretation of Air Quality Data as it relates  to NAAQS.
    PURPOSE:  Answer questions on how NAAQS and Air Quality is  related
4.  Guidelines for network design and instrument siting
    PURPOSE:  Network design and instrument siting criteria
5.  Guidelines for selection of air monitoring instruments.
    PURPOSE:  Selection of instruments
6.  Guidelines for evaluation of air quality trends
    PURPOSE:  Trend evaluation
7.  Guidelines for the evaluation of air quality data
    PURPOSE:  Evaluation methodology
8.  Guidelines for complex source monitoring
9.  Evaluation of SIP monitoring requirements

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Enclosure #4

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                                             Enclosure #
CATALOG OF PROGRAMS as of OG/01/73

APRAC - A short-term Urban Diffusion Model that calculates the
        automotive contribution to Carbon Monoxide.  The model
        was developed by Stanford Research Institute (SRI).
        A 120 page manual is available on the model.
HIWA'.Y -
PTMAX -
PTD/S
PTMTP


READT
A model that calculates a pollutant concentration
in the vicinity of a roadway.  The model is
self-documenting.

An interactive program which performs nn analysis of
the maximum, short-term concentration from a point
source as a function of stability and wind speed.

An interactive program which computes short-term
concentrations downwind from a point source at
distances specified by the user.

An interactive program which computes, at multiple
receptors, short term concentrations resulting from
multiple point sources.

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